Retail Supplier Seeks Clarification Of New Marketing Standards

November 6, 2020

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Copyright 2010-20 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Vistra Corp. requested from the Connecticut PURA clarification regarding the communication of newly approved electric distribution company standard service rates to customers pursuant to the Public Utilities Regulatory Authority's ("Authority") Connecticut Electric Supplier Marketing Standards, effective August 6, 2020, ("Marketing Standards") adopted as part of PURA's May 6, 2020 Decision ("Decision") in Docket 14-07-20RE01

Vistra's request is prompted by the approval of new default service rates prior to the period contemplated in the marketing standards concerning when suppliers must use the new default service rates in customer communications.

Vistra noted that, Section C.4 of the Marketing Standards requires a supplier to, "update all verbal and electronic marketing materials disclosing the EDC standard service price immediately upon PURA's approval of a new standard service price." Similarly, the, "use of printed marketing materials with the expiring EDC standard service price must be updated to reflect the new standard service price or be discontinued within five (5) days of PURA's approval of the new standard service price," Vistra noted

Vistra said that Sections E.3 (related to door-to-door sales) and F.3 (related to outbound and inbound telesales calls) of the Marketing Standards require that, "prior to initiating the third-party verification, each Electric Supplier shall inform the customer or potential customer…what the standard service rate is on the date of the ... call in cents per kilowatt hour, and, if the…call is being conducted within 45 calendar days of a change to the standard service rate, the date that the standard service rate will change and what the standard service rate will be on that date in cents per kilowatt hour..."

Vistra noted that, on November 3, 2020, the Authority approved the standard service rates of The United Illuminating Company (UI) for effect on January 1, 2021. Vistra noted that this approval is 59 calendar days prior to the change of the standard service rates.

"As the Authority approved UI's standard service rates more than 45 days prior to the change of the standard service rates, Sections E.3 and F.3 are internally inconsistent with Section C.4 of the Marketing Standards. A supplier cannot both immediately update verbal marketing disclosing UI's new standard service rates (as required by Section C.4) and also wait until 45 calendar days prior to the change to the standard service rates (as required by Sections E.3 and F.3)," Vistra said

"Vistra believes it was the Authority's intent of the Decision to require suppliers to disclose the newly approved standard service rates as soon as reasonably possible to better inform customers when making electric supply decisions. For instance, the Authority stated in its Decision that it 'finds it reasonable for suppliers to both monitor and be aware of changes in the standard service price and reflect those changes in the supplier's marketing.' Nevertheless, due to the internal inconsistencies of the Marketing Standards for standard service rates approved more than 45 days prior to the effective date, Vistra hereby seeks confirmation from the Authority that it can begin telling residential customers and prospective residential customers in door-to-door sales and telesales of UI's newly approved standard service rates as soon as possible. If the Authority approves Eversource's standard service rates prior to November 17, 2020 (i.e., 45 days prior to January 1, 2021), Vistra would follow the same process described above for UI," Vistra said

"In addition, Section C.5 of the Marketing Standards requires that 'the renewal notification must state the renewal rate and offer as a comparison the standard service rate applicable at the time the renewal rate will become effective.' Vistra is now in the process of updating its renewal letters to reflect the newly approved UI standard service rates, effective January 1, 2021. However, Vistra notes that the Authority still has not yet approved Eversource's standard service rates. As such, only the current Eversource standard service rates, along with a note that the current standard service rates may change on January 1st, can be included in renewal letters. Once the Authority approves Eversource's new standard service rates, Vistra will similarly work to update its renewal letters. In all instances, Vistra will continue to abide by the timelines described in Connecticut General Statutes Section 16-245o(h)(8) and will make the rolling updates to its renewal letters that are specified in Section C.5 of the Marketing Standards as those updates are approved by the Authority," Vistra said

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